In a rare blog posting, Apple listed a series of inaccuracies in the "Paradise Papers" tax story reported by the International Consortium of Investigative Journalists, while outlining its business in Cork, Ireland; emphasizing that the company is the "largest taxpayer in the world" and repeating that it "pays every dollar it owes in every country around the world."

Earlier today, AppleInsiderreported, based on an article by the Guardian citing the ICIJ's Paradise Papers investigation, that Apple has "shifted a holding firm to Jersey [in the UK Channel Islands] to protect $252B from taxation."

The Guardian report specifically noted that "Apple has done nothing illegal," but in an homage to 2016 election reporting said the story is "likely to raise fresh questions for the technology company, which has been forced to defend its tax affairs."

The report also stated that Apple had "defended the new arrangements and said they had not decreased the company's tax payment anywhere in the world," adding a company statement that "the debate over Apple's taxes is not about how much we owe but where we owe it."

Irish subsidiaries moving to Jersey did not reduce tax payments

In a rebuttal titled "The facts about Apple's tax payments," the iPhone maker flatly outlined that "the changes Apple made to its corporate structure in 2015 were specially designed to preserve its tax payments to the United States, not to reduce its taxes anywhere else. No operations or investments were moved from Ireland."

Steve Jobs' 1980 visit to Apple's new facility in Cork, Ireland

The company noted that its presence in Ireland dates back to 1980, when "Steve Jobs looked for a base to expand outside the US. The facility in Cork, Ireland started with 60 employees and now has over 6,000. Apple's innovation and investment supports a further 12,000 jobs across Ireland. And across Europe, Apple supports more than 1.5 million jobs."

It then expand upon the situation, explaining that "when Ireland changed its tax laws in 2015, we complied by changing the residency of our Irish subsidiaries and we informed Ireland, the European Commission and the United States."

The changes made "did not reduce our tax payments in any country," Apple said. "In fact, our payments to Ireland increased significantly and over the last three years we've paid $1.5 billion in tax there -- 7 percent of all corporate income taxes paid in that country. Our changes also ensured that our tax obligation to the United States was not reduced."

"Apple is the largest taxpayer in the world"

The company also emphasized that rather than evading taxation anywhere, "Apple is the largest taxpayer in the world, paying over $35 billion in corporate income taxes in the last three years. Apple pays taxes in every country where we sell our products."Apple's worldwide effective tax rate is 24.6 percent, higher than average for US multinationals

It stated, "when a customer buys an Apple product outside the United States, the profit is first taxed in the country where the sale takes place," which would include local sales taxes or VAT, as well as the property taxes and payroll taxes Apple pays as part of its retail business in various countries.

"Then Apple pays taxes to Ireland, where Apple sales and distribution activity is executed by some of the 6,000 employees working there," the company stated. "Additional tax is then also due in the US when the earnings are repatriated. Apple's worldwide effective tax rate is 24.6 percent, higher than average for US multinationals."

Dispute is over who gets Apple's tax payments

Apple's statement took issue with the idea that it is "untouched by the United States," noting that it "pays billions of dollars in taxes to the US at the statutory 35 percent rate on investment income from its overseas cash." It also added that "Apple's effective tax rate on foreign earnings is 21 percent -- a figure easily calculated from public filings. This rate has been consistent for many years."

It explained that "under the current international tax system, profits are taxed based on where the value is created. The taxes Apple pays to countries around the world are based on that principle. The vast majority of the value in our products is indisputably created in the United States -- where we do our design, development, engineering work and much more -- so the majority of our taxes are owed to the US."

The European Union sought to impose higher taxes on Apple in Ireland, claiming that Irish tax law constituted "illegal state aid." However, that effort was an attempt by the EU to tax holdings that are reserved for paying taxes to the US, and the dispute was with the EU and Ireland, not a legal issue with Apple.

That effort triggered the Obama Administration's Department fo the Treasury to issue a statement of concern regarding the possibility that "any repayments ordered by the [EU] Commission will be considered foreign income taxes that are creditable against U.S. taxes owed by the companies in the United States.

"If so, the companies' U.S. tax liability would be reduced dollar for dollar by these recoveries when their offshore earnings are repatriated or treated as repatriated as part of possible U.S. tax reform. To the extent that such foreign taxes are imposed on income that should not have been attributable to the relevant Member State, that outcome is deeply troubling, as it would effectively constitute a transfer of revenue to the EU from the U.S. government and its taxpayers."

Tax reform should "ensure certainty of law for taxpayers"

Apple added, "we understand that some would like to change the tax system so multinationals' taxes are spread differently across the countries where they operate, and we know that reasonable people can have different views about how this should work in the future.

"At Apple we follow the laws, and if the system changes we will comply. We strongly support efforts from the global community toward comprehensive international tax reform and a far simpler system, and we will continue to advocate for that."

It concluded, "Apple believes comprehensive international tax reform is essential, and for many years has been advocating for simplification of the tax code. Reform that allows a free flow of capital will accelerate economic growth and support job creation. A coordinated legislative effort internationally will remove the current tug of war between countries over tax payments and ensure certainty of law for taxpayers."

Comments

The problem is not so far away from incentives given to companies in ever state to attract their business from another place. On a much larger scale obviously and only for the bigger companies but still, it shows that if a state or country will allow companies to profit from the system, obviously companies will do it. Is it legal? Probably. Moral? Not really. But logical and to be expected from any giant multinational company. If there is a loophole, it is there to be used. The solution is to close the loophole.

This is a damage control statement. The article by the BBC is a damning revelation that leaves Apple in a bad moral light.

The questionnaire leak alone paints a picture which will make everyone in PR at Apple squirm.

This is going to be like quicksand in the sense that any move to defend itself will probably make things worse. Just like this statement has done. I can see it being torn apart line by line for deliberately trying to distract from the reality that the leaks have put onto the table.

This is a damage control statement. The article by the BBC is a damning revelation that leaves Apple in a bad moral light.

The questionnaire leak alone paints a picture which will make everyone in PR at Apple squirm.

This is going to be like quicksand in the sense that any move to defend itself will probably make things worse. Just like this statement has done. I can see it being torn apart line by line for deliberately trying to distract from the reality that the leaks have put onto the table.

Apple has been the largest tax payer in the world this isn’t news.

iPhone X sales are off the charts and more to come from other products. This is “damage control” from the iKnockoff paid media.

The fact that Apple is the largest tax payer in the world seems entirely irrelevant to me. I don't know the details of the allegations and have no opinion at the moment, but the fact that you pay a lot of taxes means only that you are very rich, not that you you are innocent of any bad behavior.

Why is it so high a tax rate for US company to bring home earnings? It’s like the US Government doesn’t want US multinational company to bring back any earnings to the US. High repatriation tax rate makes company looks for loopholes to pay less taxes. The US Congress should be saying “we see what’s happening; let’s reduce repatriation tax rate to make is easy for company to bring back earning from abroad so these companies can use the money to create more jobs” or something to that nature. It boggles my mind the stupidity of high repatriation tax rate.

The problem is not so far away from incentives given to companies in ever state to attract their business from another place. On a much larger scale obviously and only for the bigger companies but still, it shows that if a state or country will allow companies to profit from the system, obviously companies will do it. Is it legal? Probably. Moral? Not really. But logical and to be expected from any giant multinational company. If there is a loophole, it is there to be used. The solution is to close the loophole.

There is nothing moral or immoral about how taxes are collected/paid. That is a value judgement based on who should be paying and how much they should pay in comparison to others, not a legal opinion.

If governments around the world substituted a national sales tax (VAT) for all production (income) taxes all doubt over where taxes are accrued/paid is eliminated. If the product did not sell in a particular jurisdiction there would be no taxes owing to that jurisdiction except for the sales tax collected.

But no. those that feel corporations and the wealthy should pay a disportioncate amount of tax want taxes based on income, not consumption.

It is the very concept of taxing production that leads to special interest loopholes/exemptions, etc that makes the world's tax system inherently unfair to all, and horribly complex to the point that NOBODY, not even the IRS in the US, can correctly complete a tax return.

In my opinion the only entities that should pay taxes are those that have the right to vote. The US fought for independence from Great Britain over the issue of taxation without representation.

This is a damage control statement. The article by the BBC is a damning revelation that leaves Apple in a bad moral light.

The questionnaire leak alone paints a picture which will make everyone in PR at Apple squirm.

This is going to be like quicksand in the sense that any move to defend itself will probably make things worse. Just like this statement has done. I can see it being torn apart line by line for deliberately trying to distract from the reality that the leaks have put onto the table.

What leaks????? Apple's rebuttal specifically states that when the move the Jersey was made Apple notified Ireland, the EU and the US. Seems to me that Apple's move was fully transparent and there was no attempt to hide its actions.

Why is it so high a tax rate for US company to bring home earnings? It’s like the US Government doesn’t want US multinational company to bring back any earnings to the US. High repatriation tax rate makes company looks for loopholes to pay less taxes. The US Congress should be saying “we see what’s happening; let’s reduce repatriation tax rate to make is easy for company to bring back earning from abroad so these companies can use the money to create more jobs” or something to that nature. It boggles my mind the stupidity of high repatriation tax rate.

Ah, a logical response, not an emotional response. I love it. You are entirely correct, the US tax system was created when international sales were not as extensive as they are today. It is a relic of pre WWII economies and does not reflect the world economic zone that we live in today.

Eliminating the philosophy of taxing production (income taxes in all of its various forms) in favor of consumption taxes (national sales tax/VAT) eliminates all issues of how much and to whom the taxes are owed. If one country wishes a higher sales tax than another, then so be it. Eliminating production taxes reduces the cost of production. PRODUCTION TAXES ARE A COST OF DOING BUSINESS that is not created in a vacuum. ALL BUSINESS COSTS are passed on to the consumer in the form of higher prices.

In the US elimination of production taxes will reduce the retail price of US made products by about 25% (yes its that high when you take into account all the various taxes paid that are based on profits). A national sales tax of 25% brings the retail cost of a US made product, consumed in the US back up to its starting point. Its a zero sum game.

A national consumption tax also eliminates PERSONAL income taxes and eliminates the need for special, tax deferred, restricted use, retirement savings accounts that penalize those that haven't the financial capability/flexibility to salt monies away for 40+ years for retirement.

This is a damage control statement. The article by the BBC is a damning revelation that leaves Apple in a bad moral light.

The questionnaire leak alone paints a picture which will make everyone in PR at Apple squirm.

This is going to be like quicksand in the sense that any move to defend itself will probably make things worse. Just like this statement has done. I can see it being torn apart line by line for deliberately trying to distract from the reality that the leaks have put onto the table.

Apple has been the largest tax payer in the world this isn’t news.

iPhone X sales are off the charts and more to come from other products. This is “damage control” from the iKnockoff paid media.

If you wanted to defend Apple you could have tried to tackle what is actually in the news. The leaked information, instead of rehashing Apple's PR.

In that regard, Apple says, and let's be clear on this, 'initial sales' are 'off the charts'. In the earnings call TC simply described them as 'very strong'.

Sales might end up off the charts but any evaluation of that will have to wait until September next year as the current offering is all we are going a to have (in the phone segment) until then and that is all that really counts.

On the subject at hand, the devil is in the details. When TC said, and not too long ago, Apple didn't have its cash stashed away on some Caribbean island, he obviously didn't count on the Paradise Papers possibility. Now, rightly or wrongly, people will look at that claim and use it against him.

Why is it so high a tax rate for US company to bring home earnings? It’s like the US Government doesn’t want US multinational company to bring back any earnings to the US. High repatriation tax rate makes company looks for loopholes to pay less taxes. The US Congress should be saying “we see what’s happening; let’s reduce repatriation tax rate to make is easy for company to bring back earning from abroad so these companies can use the money to create more jobs” or something to that nature. It boggles my mind the stupidity of high repatriation tax rate.

I take a slightly different viewpoint. Earnings are made in tax years and rules apply to those years. Whatever the rules are, companies in any given tax jurisdiction, should abide by those rules and push for a change in tax legislation if they consider them to be unfair.

From a moral perspective, I believe witholding payment of taxes until such a time is 'right' for the company, is wrong. As is the idea that a company itself, can determine how much to make available for taxation. Especially if that same option is not open to competitors.

You can be sure that some here will roll out the shareholder argument and that Apple must do all it can to maximise it's return to shareholders, even if it means employing questionable accounting practices. That is missing the point entirely.

This is a damage control statement. The article by the BBC is a damning revelation that leaves Apple in a bad moral light.

The questionnaire leak alone paints a picture which will make everyone in PR at Apple squirm.

This is going to be like quicksand in the sense that any move to defend itself will probably make things worse. Just like this statement has done. I can see it being torn apart line by line for deliberately trying to distract from the reality that the leaks have put onto the table.

What leaks????? Apple's rebuttal specifically states that when the move the Jersey was made Apple notified Ireland, the EU and the US. Seems to me that Apple's move was fully transparent and there was no attempt to hide its actions.

This is a damage control statement. The article by the BBC is a damning revelation that leaves Apple in a bad moral light.

The questionnaire leak alone paints a picture which will make everyone in PR at Apple squirm.

This is going to be like quicksand in the sense that any move to defend itself will probably make things worse. Just like this statement has done. I can see it being torn apart line by line for deliberately trying to distract from the reality that the leaks have put onto the table.

The fact is that Apple is engaging in the time-honoured tradition of tax avoidance which is perfectly legal. In fact, everyone in the leaked documents is engaged in legal tax avoidance. Hell, if I could afford a high-falluttin’ tax barrister, I’d be engaged in legal tax avoidance.

This is happens every couple of years: documents get leaked, companies and individuals get exposed (and in this case, there’s nothing here on Apple that we didn’t already know), the press boils the public into a frenzy, and the governments do nothing to close the loopholes. Why? Because politicians are using the exact same loopholes to avoid paying taxes to the people they’re elected to serve.

As much as you would like this to result in the downfall of Apple, I’m afraid it won’t. Apple is probably the most conservative company when it comes to accounting. They assume that all the tax they avoid (yes, that is what they’re doing) does not belong to them and so it is still counted as a liability. If they had to pay it tomorrow, it wouldn’t make a ripple on the balance sheet, and tomorrow everyone will move onto something else … until next year’s leak.

What I have noticed is that every time this happens, there is less outrage, fewer calls for heads on pikes, less of an impetus to do anything about it. Corporate tax avoidance is fading into the background of public consciousness. In that regard, it is enjoying the same fading shock value as mass shootings, but in my book, legal tax avoidance is far less serious.

This is a damage control statement. The article by the BBC is a damning revelation that leaves Apple in a bad moral light.

The questionnaire leak alone paints a picture which will make everyone in PR at Apple squirm.

This is going to be like quicksand in the sense that any move to defend itself will probably make things worse. Just like this statement has done. I can see it being torn apart line by line for deliberately trying to distract from the reality that the leaks have put onto the table.

Apple has been the largest tax payer in the world this isn’t news.

iPhone X sales are off the charts and more to come from other products. This is “damage control” from the iKnockoff paid media.

If you wanted to defend Apple you could have tried to tackle what is actually in the news. The leaked information, instead of rehashing Apple's PR.

In that regard, Apple says, and let's be clear on this, 'initial sales' are 'off the charts'. In the earnings call TC simply described them as 'very strong'.

He might not be going by what Cook says, but by what Apple gave as its guidance for next quarter.

The fact that Apple is the largest tax payer in the world seems entirely irrelevant to me. I don't know the details of the allegations and have no opinion at the moment, but the fact that you pay a lot of taxes means only that you are very rich, not that you you are innocent of any bad behavior.

And yet other huge corporations manage to pay zero taxes some years. It's relevant and important to remind people of plain facts at times.

Why is it so high a tax rate for US company to bring home earnings? It’s like the US Government doesn’t want US multinational company to bring back any earnings to the US. High repatriation tax rate makes company looks for loopholes to pay less taxes. The US Congress should be saying “we see what’s happening; let’s reduce repatriation tax rate to make is easy for company to bring back earning from abroad so these companies can use the money to create more jobs” or something to that nature. It boggles my mind the stupidity of high repatriation tax rate.

I take a slightly different viewpoint. Earnings are made in tax years and rules apply to those years. Whatever the rules are, companies in any given tax jurisdiction, should abide by those rules and push for a change in tax legislation if they consider them to be unfair.

From a moral perspective, I believe witholding payment of taxes until such a time is 'right' for the company, is wrong. As is the idea that a company itself, can determine how much to make available for taxation. Especially if that same option is not open to competitors.

You can be sure that some here will roll out the shareholder argument and that Apple must do all it can to maximise it's return to shareholders, even if it means employing questionable accounting practices. That is missing the point entirely.

When you do your own taxes do you ever decide late in the year to add more money to a tax deferred account or perhaps time your sale of assets to defer taxes by 1 year? If not, you're a fool. The tax laws lay out what is permissible. Taking advantage of every possibility to reduce or defer taxes within those boundaries is the only smart thing to do.

This is a damage control statement. The article by the BBC is a damning revelation that leaves Apple in a bad moral light.

The questionnaire leak alone paints a picture which will make everyone in PR at Apple squirm.

This is going to be like quicksand in the sense that any move to defend itself will probably make things worse. Just like this statement has done. I can see it being torn apart line by line for deliberately trying to distract from the reality that the leaks have put onto the table.

Apple has been the largest tax payer in the world this isn’t news.

iPhone X sales are off the charts and more to come from other products. This is “damage control” from the iKnockoff paid media.

If you wanted to defend Apple you could have tried to tackle what is actually in the news. The leaked information, instead of rehashing Apple's PR.

In that regard, Apple says, and let's be clear on this, 'initial sales' are 'off the charts'. In the earnings call TC simply described them as 'very strong'.

He might not be going by what Cook says, but by what Apple gave as its guidance for next quarter.

Which is for Apple's entire product catalogue and services, for just one quarter and not just for the iPhone X.

This will never end or change. As no-one in power wants to be the first to close the loopholes in their own country - it would be financial suicide.Also those in power also make full use of these loopholes.

It would need an borderless, international effort to change the rules and that's never gonna happen... until 'merica takes over the world of course.

Why is it so high a tax rate for US company to bring home earnings? It’s like the US Government doesn’t want US multinational company to bring back any earnings to the US. High repatriation tax rate makes company looks for loopholes to pay less taxes. The US Congress should be saying “we see what’s happening; let’s reduce repatriation tax rate to make is easy for company to bring back earning from abroad so these companies can use the money to create more jobs” or something to that nature. It boggles my mind the stupidity of high repatriation tax rate.

I take a slightly different viewpoint. Earnings are made in tax years and rules apply to those years. Whatever the rules are, companies in any given tax jurisdiction, should abide by those rules and push for a change in tax legislation if they consider them to be unfair.

From a moral perspective, I believe witholding payment of taxes until such a time is 'right' for the company, is wrong. As is the idea that a company itself, can determine how much to make available for taxation. Especially if that same option is not open to competitors.

You can be sure that some here will roll out the shareholder argument and that Apple must do all it can to maximise it's return to shareholders, even if it means employing questionable accounting practices. That is missing the point entirely.

You seem to have a very loose grip on this situation. What Apple is doing is deferring taxes by holding profits outside the US. That’s legal, and for very good reason. US companies that earn profits outside the US have the option of spending those profits outside the US, to grow operations, build factories or retail outlets, acquire companies, etc. Profit so spent will never be repatriated and therefore will never be subject to US taxes. And indeed, Apple does invest/spend some of its foreign profits in this manner. So companies have a perfect right to hold profits overseas while weighing their best use. In Apple’s case, the company apparently feels that a change to the tax rate for repatriated profits would tip the balance toward repatriating a significant amount of those profits, but without a reduction in the tax rate feels it should wait, keeping its options open. The rest is merely the specific mechanics of where the profits are domiciled to be held outside the US. And there’s nothing illegal about Apple’s practices in that regard, nor is what Apple doing something not available to any other corporation that wishes to apply the resources (tax experts) to do so. In fact, it’s been reported that many other corporations do exactly the same, including Google, GE, etc.

Why is it so high a tax rate for US company to bring home earnings? It’s like the US Government doesn’t want US multinational company to bring back any earnings to the US. High repatriation tax rate makes company looks for loopholes to pay less taxes. The US Congress should be saying “we see what’s happening; let’s reduce repatriation tax rate to make is easy for company to bring back earning from abroad so these companies can use the money to create more jobs” or something to that nature. It boggles my mind the stupidity of high repatriation tax rate.

I take a slightly different viewpoint. Earnings are made in tax years and rules apply to those years. Whatever the rules are, companies in any given tax jurisdiction, should abide by those rules and push for a change in tax legislation if they consider them to be unfair.

From a moral perspective, I believe witholding payment of taxes until such a time is 'right' for the company, is wrong. As is the idea that a company itself, can determine how much to make available for taxation. Especially if that same option is not open to competitors.

You can be sure that some here will roll out the shareholder argument and that Apple must do all it can to maximise it's return to shareholders, even if it means employing questionable accounting practices. That is missing the point entirely.

When you do your own taxes do you ever decide late in the year to add more money to a tax deferred account or perhaps time your sale of assets to defer taxes by 1 year? If not, you're a fool. The tax laws lay out what is permissible. Taking advantage of every possibility to reduce or defer taxes within those boundaries is the only smart thing to do.

I suspect Avon B7 doesn’t grok that this is a tax deferral issue. Many seem to believe Apple is somehow avoiding taxes rather than merely deferring them. You’d think he be up to speed; the guy comments on pretty much every AI article, has been around for years... but some folks never catch on, and that betrays an ulterior motive/agenda.